United States - The US IRS Publishes Regulations on Hybrid Instruments and Entities
- United States
- P. Carman
- Derivatives & Financial Instruments, 2019 (Volume 21), No 4
- 2 July 2019
On 28 December 2018, the US Internal Revenue Service (IRS) published Proposed Regulations providing details as to the new US limitations on the deductibility of payments in respect of hybrid instruments and hybrid transactions. This article discusses the new rules extensively.